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JANIS v. COMMISSIONER OF INTERNAL REVENUE

No. 04-74624.

461 F.3d 1080 (2006)

Conrad JANIS; Maria G. Janis, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed August 21, 2006.

Attorney(s) appearing for the Case

Steven R. Mather and Elliott H. Kajan, Kajan Mather and Barish, Beverly Hills, CA, for the petitioners.

Eileen J. O'Connor, Assistant Attorney General, Jonathan S. Cohen and Francesca U. Tamami, Attorneys, Department of Justice, Tax Division, Washington, D.C., for the respondent.

Before STEPHEN REINHARDT, STEPHEN S. TROTT, and M. MARGARET McKEOWN, Circuit Judges.

McKEOWN, Circuit Judge.

Conrad Janis and his wife Maria G. Janis ("Petitioners") appeal the Tax Court's holding that they are liable for deficiencies in their joint income tax returns from 1995 through 1997. These deficiencies resulted from Conrad taking inconsistent positions as to the value of an expensive art collection included in his father's estate. On the premise that flooding the market with a large collection of...

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